By Welton Hong, founder and CEO of Ring Ring Marketing
For years, online reviews have been treated as a marketing tool.
Today, they’re something much bigger.
Reviews have become one of the primary signals that Google, artificial intelligence platforms and consumers use to determine which businesses deserve trust. When someone asks ChatGPT, Google AI Overviews or another AI assistant to recommend a funeral home, those systems don’t just look at your website. They analyze your reputation across Google, Facebook, Yelp, the Better Business Bureau and other review platforms to determine whether your business appears credible.
That’s exactly why the Federal Trade Commission has dramatically increased its scrutiny of fake and deceptive reviews.
And the potential financial consequences are staggering.
The FTC’s Trade Regulation Rule on the Use of Consumer Reviews and Testimonials took effect on Oct. 21, 2024, giving the agency the ability to seek civil penalties for businesses that knowingly violate the rule. For 2026, the maximum civil penalty has been adjusted for inflation to $53,088 per violation — meaning multiple improper reviews could expose a business to hundreds of thousands of dollars in potential liability.
Why the FTC Changed the Rules
The FTC spent years watching online reviews become increasingly unreliable.
Some businesses bought glowing five-star reviews. Others hired overseas companies to manufacture testimonials. Artificial intelligence made it possible to generate convincing fake reviews by the thousands. Some companies pressured dissatisfied customers into removing negative comments or only solicited reviews from people they knew would leave positive feedback.
The FTC concluded that these practices distort competition and deceive consumers who rely heavily on reviews when making purchasing decisions.
Rather than relying solely on traditional deceptive advertising laws, the agency created a specific rule targeting fake reviews and testimonials. That matters because the rule gives the FTC a much stronger enforcement mechanism than it previously had.
The Mistake Some Funeral Homes Still Make
Here’s where some funeral homes misunderstand the rules.
Some owners believe it’s acceptable for employees to leave Google reviews as long as they disclose that they work for the funeral home.
That’s a dangerous assumption.
Even if an employee openly identifies themselves as an employee, Google generally considers employee reviews to present an inherent conflict of interest and may remove them under its own review policies. At the same time, the FTC rule places significant restrictions on insider testimonials and reviews, particularly those involving officers, managers and employees whose relationship to the business creates a material connection.
In other words, transparency alone doesn’t necessarily solve the problem.
If your funeral home has encouraged staff members to boost your Google rating, you’re venturing into risky territory.
The Practices Every Funeral Home Should Avoid
The obvious violations are easy to spot.
- Never purchase reviews.
- Never pay someone to post a positive review.
- Never generate reviews using artificial intelligence and present them as genuine customer experiences.
- Never ask friends or relatives who have never used your services to leave reviews.
But some practices are more subtle.
Offering a gift card only if someone leaves a five-star review can violate the rule because the incentive is tied to a particular sentiment. Likewise, suppressing legitimate negative reviews through intimidation, baseless legal threats or selectively publishing only favorable reviews can also create regulatory problems. Businesses also cannot create websites that appear to provide independent reviews when they actually control the content.
Where Funeral Homes Should Get Reviews Instead
Fortunately, building a strong online reputation doesn’t require shortcuts.
The best reviews come from the people who genuinely experienced your services.
That includes families you’ve served.
It includes hospice professionals, clergy members, celebrants and other referral partners who have firsthand knowledge of your professionalism.
These individuals can speak authentically about their experiences. That’s exactly the kind of feedback consumers trust and search platforms increasingly reward.
Meanwhile, employees who want to support your organization still have appropriate outlets. Company culture reviews on employment sites such as Glassdoor or Indeed can help with recruiting because those platforms are designed for employee perspectives. But employees should never be viewed as a source of consumer reviews for your funeral home’s Google Business Profile.
Reviews Have Become AI Training Data
This is perhaps the biggest shift many funeral directors haven’t fully appreciated.
Reviews are no longer simply social proof for prospective families.
They have become part of the data that search engines and AI systems analyze when deciding which businesses deserve recommendations.
That means authenticity matters more than ever.
Artificial intelligence is becoming increasingly sophisticated at identifying patterns associated with suspicious review activity. At the same time, Google continues investing heavily in systems that detect review spam and remove questionable submissions.
Trying to game the system may produce a temporary ratings boost, but it creates long-term reputational risk with both regulators and search algorithms.
What Happens If the FTC Contacts Your Funeral Home?
Receiving an inquiry from the FTC doesn’t automatically mean your funeral home will be fined.
Typically, the process begins with an investigation after the agency receives complaints, referral information or develops evidence suggesting possible violations. The FTC may issue a Civil Investigative Demand or other requests for documents, communications and internal policies related to your review practices. The agency evaluates whether the business knowingly engaged in conduct prohibited by the rule before deciding whether to pursue enforcement.
If the FTC seeks civil penalties, it generally must do so in federal court, where the government presents its case and the court determines whether violations occurred and what penalties, if any, are appropriate. Maximum penalties are not automatic; courts consider the facts and circumstances of each case. Many investigations are resolved through negotiated settlements or consent orders requiring businesses to change their practices, although more serious cases can result in litigation and substantial financial penalties.
If your funeral home is contacted by the FTC, resist the temptation to respond casually or destroy records.
Instead, preserve all relevant documents, suspend any questionable review-generation activities, notify your attorney immediately and cooperate thoughtfully with the investigation. If you use an outside marketing agency, involve them early so review campaigns, policies and communications can be evaluated together.
Trust Is Still Your Greatest Marketing Asset
The funeral profession has always depended on reputation.
The difference today is that reputation has become measurable, searchable and increasingly regulated.
Authenticity has always been good ethics.
Now it’s also good compliance.
And considering that each knowing violation could potentially cost up to $53,088, it’s one of the best investments your funeral home can make.
Welton Hong is the founder & CEO of Ring Ring Marketing, which has helped over 600 small businesses grow their revenue through online marketing strategies. He is also the author of “Making Your Phone Ring with Internet Marketing for Funeral Homes.” Visit ringringmarketing.com and follow the company on Facebook, LinkedIn, Instagram and X.
